Grants to Individuals

Internal Revenue Service
P.O. Box 2508
Cincinnati, OH 45201
Date: October 13, 2020
Number: 202101009
Release Date: 1/8/2021
LEGEND
X=
Y=
Z=
Dear
Department of the Treasury
Employer Identification Number:
Contact person - ID number:
Contact telephone number:
UIL: 4945.04-04
You asked for advance approval of your employer-related scholarship grant procedures under Internal Revenue Code Section 4945(g). This approval is required because you are a private foundation that is exempt from federal income tax. You requested approval of your scholarship program to fund the education of certain qualifying students.
Our determination
We approved your procedures for awarding employer-related scholarships. Based on the information you submitted, and assuming you will conduct your program as proposed, we determined that your procedures for awarding employer-related scholarships meet the requirements of Code Section 4945(g)(1 ). As a result, expenditures you make under these procedures won't be taxable.
Also, awards made under these procedures are scholarship or fellowship grants and are not taxable to the recipients if they use them for qualified tuition and related expenses (subject to the limitations provided in Code Section 11 ?(b)).
Description of your request
Your letter indicates that you will operate an educational grant program called the X.
The X was created pursuant to an agreement between you, Y, and Z. The purpose of X is to award grants to graduating high school seniors furthering their education at a qualified postsecondary educational institution who are also the children and/or grandchildren of active, retired, or deceased employees of the Y.
At a minimum, you represent that two grants will be paid directly to recipients and may be used for tuition, fees, and/or room and board while pursuing an undergraduate degree in any field. Grants are not renewable.
Letter 4793 (10-2012)
Catalog Number 58264E